PTAB

IPR2019-01434

Comcast Cable Communications LLC v. Rovi Guides Inc

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Relocating Media
  • Brief Description: The ’069 patent describes a method and system for an interactive media guide that allows a user to pause or "freeze" media content on a first device, store the position information, and later resume playback on a second device from the paused position or other selectable points.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 9-14, and 19-20 are obvious over Goode and Vallone

  • Prior Art Relied Upon: Goode (Patent 6,166,730) and Vallone (Patent 6,847,778).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goode taught the core functionality of the challenged claims: an on-demand system where a user can pause media on a first set-top terminal, have the pause position bookmarked and stored on a network server, and subsequently resume playback from that bookmarked position on a second set-top terminal. Petitioner contended that Goode, however, did not explicitly disclose the claimed user interface feature of generating a simultaneous display of multiple playback options (e.g., resume from pause point, resume from a point prior to the pause point). Vallone was argued to supply this missing element by teaching a "trick play bar" that displays multiple bookmark indicators, allowing a user to see and select from various stored pause points within the media content.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Goode and Vallone to provide the user with greater and more flexible playback control. Vallone's interface, which simultaneously displays multiple playback options on a single screen, would be a predictable and advantageous improvement to Goode's system, allowing users to more quickly and easily select a desired resume point.
    • Expectation of Success: A POSA would have a reasonable expectation of success in combining the references because both Goode and Vallone describe similar bookmark-based media playback systems that use user interfaces to receive commands. Integrating Vallone's trick play bar display into Goode’s system would be a simple software modification to yield the predictable result of an enhanced user interface.

Ground 2: Claims 1-4, 9-14, and 19-20 are obvious over Goode and Hwang

  • Prior Art Relied Upon: Goode (Patent 6,166,730) and Hwang ("Video Browsing for Course-On-Demand in Distance Learning," a 1997 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative to the Goode and Vallone combination. As in Ground 1, Petitioner relied on Goode to teach the foundational system of pausing on one device and resuming on another. Hwang was argued to teach the missing user interface element of simultaneously displaying multiple playback options. Specifically, Hwang's interface for educational video browsing was shown to include both a "CONTINUE" button (a first option to resume from a pause point) and a "RESET" button (a second option to start from the beginning), which were displayed simultaneously.
    • Motivation to Combine: A POSA would be motivated to supplement Goode’s interface with Hwang’s interface to facilitate greater playback control. By displaying multiple options like "CONTINUE" and "RESET" together, the user is given more control over where playback resumes. Implementing such a known display method, as evidenced by Hwang, into Goode's system would be a common-sense improvement.
    • Expectation of Success: There would be a high expectation of success because both Goode and Hwang describe systems for playing and resuming video content. Modifying Goode's software to incorporate a well-understood user interface design, like the one in Hwang, would be a straightforward task for a POSA to achieve the predictable result of enhanced user control.

Ground 3: Claims 5 and 15 are obvious over Goode in view of Vallone and Sato

  • Prior Art Relied Upon: Goode (Patent 6,166,730), Vallone (Patent 6,847,778), and Sato (Japanese App. Pub. No. H10-79930).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Goode and Vallone to address the limitations of claims 5 and 15, which require generating a "relocate option" on the first device. Petitioner asserted that the Goode/Vallone combination was consistent with this concept but might lack an explicit disclosure. Sato was introduced to teach this feature, as it describes a system that, upon a user stopping video playback, explicitly queries the user whether to register the video stop position information. This query was argued to be the claimed "relocate option."
    • Motivation to Combine: A POSA would combine Sato's registration query with the Goode/Vallone system to advantageously confirm that a user actually desires to store the pause information before doing so. This would prevent the system from saving unnecessary data and ensure that relocation bookmarks are created only when intended by the user.
    • Expectation of success: Combining these known elements would be predictable. It would involve a simple software change to add Sato's confirmation query to the Goode/Vallone system, yielding the expected result of user-confirmed data storage.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Goode, Vallone, and Chau (Patent 6,011,910) for claims requiring a user login feature, and analogous combinations using Hwang as the primary secondary reference (i.e., Goode/Hwang/Sato and Goode/Hwang/Chau). Chau was argued to teach a conventional login prompt to improve system security by authenticating users before granting access to personal content like saved bookmarks.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for two terms, noting they were for completeness and Board convenience and did not alter the petition's analysis.
    • "display": Proposed as "present visually and/or audibly."
    • "user equipment": Proposed as "one or more devices at a user site."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of the ’069 patent as unpatentable.